ARSC Meeting May 20-22, 2014

ARSC Meeting May 20-22, 2014 Agenda Item 2A Proposed Statement on Standards for Accounting and Review Services Framework for Performing and Reporting on Compilation and Review Engagements Introduction Scope 1. This section provides a framework for performing and reporting on compilation and review engagements. This section also sets forth the meaning of certain terms used in Statements on Standards for Accounting and Review Services (SSARSs) issued by the Accounting and Review Services Committee (ARSC) when describing the professional requirements imposed on accountants performing compilation and review engagements. 2. This section is intended to help accountants better understand their professional responsibilities when engaged to compile or review financial statements or financial information. Additional SSARSs have been established to set forth specific performance and reporting requirements. Such additional requirements are based on the framework provided by this standard, and any requirements created by this standard also have been incorporated into the additional SSARSs. 3. SSARSs are codified into AR sections. SSARSs are written in the context of a compilation or review of financial statements by an accountant. They are to be adapted as necessary in the circumstances when applied to compilations or reviews of other historical financial information. SSARSs do not address the responsibilities of the accountant that may exist in legislation, regulation, or otherwise. Such responsibilities may differ from those established in SSARSs. Accordingly, although the accountant may find aspects of SSARSs helpful in such circumstances, it is the responsibility of the accountant to ensure compliance with all relevant legal, regulatory, or professional obligations. Financial Statements or Financial Information 4. The financial statements subject to the compilation or review engagement are those of the entity. The entity s management is responsible for the preparation and presentation of those financial statements. SSARSs do not impose responsibilities on management and do not override laws and regulations that govern their responsibilities. However, a compilation or review of financial statements in accordance with SSARSs is conducted Prepared by: Mike Glynn (May 2014) Page 1 of 20

on the premise that management has acknowledged certain responsibilities that are fundamental to the conduct of the compilation or review engagement. The compilation or review of the financial statements does not relieve management of their responsibilities. (Ref: par. A1A9) Three-Party Relationship 5. A compilation or review engagement involves three parties: Effective Date Management (or the responsible party) (Ref: par. A10A16) An accountant in the practice of public accounting, as defined by the AICPA Code of Professional Conduct Intended users of the financial statements or financial information (Ref: par. A17A18) 6. This proposed SSARS is effective for compilations and reviews of financial statements for periods ending on or after December 15, 2015. Early implementation is permitted. Objective 7. The accountant s objective is to obtain an understanding of the framework for performing and reporting on compilation and review engagements necessary to perform and report on a compilation or review engagement. Definitions 8. For purposes of SSARSs, the following terms have the meanings attributed as follows: Accountant in the practice of public accounting. An accountant or the accountant s firm, who is a member of the AICPA, and who performs professional services for a client. 1 Engagement partner. 2 The partner or other person in the firm who is responsible for the engagement and its performance, and for the report that is issued on behalf of the firm, and who, where required, has the appropriate authority from a professional, legal, or regulatory body. Firm. A form of organization permitted by law or regulation whose characteristics conform to resolutions of the Council of the AICPA and that is engaged in the practice of public accounting. 1 Paragraphs.21 and.30 of ET section 92, Definitions (AICPA, Professional Standards) 2 Term also defined in paragraph.13 of QC section 10 for purposes of the SQCSs. Refer to QC section 10 for specific language. 2 Agenda Item 2A Page 2 of 20

Intended users of the financial statements or financial information. The person(s) or class of persons who understand the financial statements or financial information and the limitations of the compilation or review engagement and the financial statements or financial information. Interpretative publications. Compilation and review interpretations of SSARSs; exhibits to SSARSs; the AICPA Guide Compilation and Review Engagements, compilation and review guidance included in other AICPA Audit and Accounting Guides; and AICPA Statements of Position, to the extent that those statements are applicable to compilation and review engagements. Nonissuer. Any entity not subject to the Sarbanes-Oxley Act of 2002 or the rules of the SEC. Other compilation and review publications. Publications other than interpretative publications. These include AICPA accounting and review publications not defined as interpretative publications; the AICPA's annual Alert Compilation and Review Developments; compilation and review articles in the Journal of Accountancy and other professional journals; continuing professional education programs and other instructional materials, textbooks, guide books, compilation and review programs, and checklists; and other compilation and review publications from state CPA societies, other organizations, and individuals. Professional judgment. The application of relevant training, knowledge, and experience, within the context provided by Statements on Standards of Accounting and Review Services and ethical standards, in making informed decisions about the courses of action that are appropriate in the circumstances of the compilation or review engagement. Professional skepticism. An attitude that includes a questioning mind, being alert to conditions that may indicate possible misstatement due to fraud or error, and a critical assessment of evidence. Requirements Ethical Requirements Relating to a Compilation or Review of Financial Statements 9. The accountant should comply with relevant ethical requirements relating to compilation or review engagements. (Ref: par. A19A24) 10. The accountant must determine whether the accountant is independent of the entity. 11. The accountant must be independent of the entity when performing a review of financial statements in accordance with SSARSs. If, during the performance of the review engagement, the accountant determines that the accountant s independence is impaired, the accountant should withdraw from the review engagement. (Ref: par. A25) Professional Judgment 3 Agenda Item 2A Page 3 of 20

12. The accountant should exercise professional judgment in the performance of a compilation or review engagement. (Ref: par. A26A30) Conduct of the Engagement in Accordance With SSARSs 13. The accountant must perform a compilation or review engagement of a nonissuer in accordance with SSARSs, except for certain reviews of interim financial information as discussed in paragraph 3 of the proposed SSARS Review of Financial Statements. Complying With AR Sections Relevant to the Engagement 14. The accountant should comply with all AR sections relevant to the engagement. An AR section is relevant to the engagement when the AR section is in effect, and the circumstances addressed by the AR section exist. (Ref: par. A31A36) 15. The accountant should have an understanding of the entire text of an AR section, including its application and other explanatory material, to understand its objectives and apply its requirements properly. (Ref: par. A37A41) 16. An accountant should not represent compliance with SSARSs in the accountant s compilation or review report unless the accountant has complied with the requirements of this section and all other AR sections relevant to the engagement. Complying With Relevant Requirements 17. Subject to paragraph 19, the accountant should comply with each requirement of the relevant AR section unless, in the circumstances of the engagement, the requirement is not relevant because it is conditional, and the condition does not exist. (Ref: par. A42) Defining Professional Responsibilities in SSARSs 18. SSARSs use the following two categories of professional requirements, identified by specific terms, to describe the degree of responsibility they impose on accountants: Unconditional requirements. The accountant must comply with an unconditional requirement in all cases in which such requirement is relevant. SSARSs use the word must to indicate an unconditional requirement. Presumptively mandatory requirements. The accountant must comply with a presumptively mandatory requirement in all cases in which such a requirement is relevant, except in rare circumstances discussed in paragraph 19. SSARSs use the word should to indicate a presumptively mandatory requirement. (Ref: par. A43) 19. In rare circumstances, the accountant may judge it necessary to depart from a relevant presumptively mandatory requirement. In such circumstances, the accountant should perform alternative procedures to achieve the intent of the requirement. The need for an accountant to depart from a relevant presumptively mandatory requirement is expected to 4 Agenda Item 2A Page 4 of 20

arise only when the requirement is for a specific procedure to be performed and, in the specific circumstances of the engagement, that procedure would be ineffective in achieving the intent of the requirement. Interpretative Publications 20. The accountant should consider applicable interpretative publications in the performance of the compilation or review engagement. (Ref: par. A44) Other Compilation and Review Publications 21. In applying the guidance included in an other compilation and review publication, the accountant should, exercising professional judgment, assess the relevance and appropriateness of such guidance to the circumstances of the engagement. (Ref: par. A45A47) Engagement Level Quality Control 22. In a compilation or review engagement, the engagement partner should possess competence and capabilities to perform the compilation or review engagement and competence in financial reporting, appropriate to the engagement circumstances. 23. In a compilation or review engagement, the engagement partner should take responsibility for: (Ref: par. A48-A51) (a) The overall quality of each compilation or review engagement to which that partner is assigned; (b) The direction, supervision, planning and performance of the compilation or review engagement in compliance with professional standards and applicable legal and regulatory requirements; (Ref: par. A52) (c) The accountant s report being appropriate in the circumstances; and (d) The engagement being performed in accordance with the firm s quality control policies and procedures, including the following: (i) Being satisfied that appropriate procedures regarding the acceptance and continuance of client relationships and engagements have been followed, and that conclusions reached are appropriate, including considering whether there is information that would lead the engagement partner to conclude that management lacks integrity; (Ref: par. A53-A54) (ii) Being satisfied that the engagement team collectively has the appropriate competence and capabilities to perform the compilation or review engagement and expertise in financial reporting to: 5 Agenda Item 2A Page 5 of 20

a. Perform the compilation or review engagement in accordance with professional standards and applicable legal and regulatory requirements; and b. Enable a report that is appropriate in the circumstances to be issued; and (iii) Taking responsibility for appropriate engagement documentation being maintained. Relevant Considerations after Engagement Acceptance 24. If the engagement partner obtains information that would have caused the firm to decline the engagement had that information been available earlier, the engagement partner should communicate that information promptly to the firm, so that the firm and the engagement partner can take the necessary action. Compliance with Relevant Ethical Requirements 25. Throughout the engagement, the engagement partner should remain alert, through observation and making inquiries as necessary, for evidence of noncompliance with relevant ethical requirements by members of the engagement team. If matters come to the engagement partner s attention through the firm s system of quality control or otherwise that indicate that members of the engagement team have not complied with relevant ethical requirements, the engagement partner, in consultation with others in the firm, should determine the appropriate action. Monitoring 26. An effective system of quality control for a firm includes a monitoring process designed to provide the firm with reasonable assurance that the firm s policies and procedures relating to the system of quality control are relevant, adequate, and operating effectively. The engagement partner should consider the results of the firm s monitoring process as evidenced in the latest information circulated by the firm and, if applicable, other network firms and whether deficiencies noted in that information may affect the review engagement. Application and Other Explanatory Material Financial Statements or Financial Information (Ref: par. 4) A1. A compilation or review engagement in accordance with SSARSs is conducted on the premise that management has acknowledged and understands that it has responsibility a. for the preparation and fair presentation of the financial statements in accordance with the applicable financial reporting framework; 6 Agenda Item 2A Page 6 of 20

b. for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error; and c. to provide the accountant with i. access to all information of which management is aware that is relevant to the preparation and fair presentation of the financial statements, such as records, documentation, and other matters; ii. additional information that the accountant may request from management for the purpose of the compilation or review; and iii. unrestricted access to persons within the entity from whom the accountant determines it necessary to make inquiries. A2. The preparation and fair presentation of the financial statements require the identification of the applicable financial reporting framework, in the context of any relevant laws or regulations. the preparation and fair presentation of the financial statements in accordance with that framework. the inclusion of an adequate description of that framework in the financial statements. The preparation and fair presentation of the financial statements require management to exercise judgment when making accounting estimates that are reasonable in the circumstances, as well as when selecting and applying appropriate accounting policies. These judgments are made in the context of the applicable financial reporting framework. A3. The financial statements may be prepared in accordance with one of the following: A general purpose framework (a financial reporting framework designed to meet the common financial information needs of a wide range of users) A special purpose framework A4. The applicable financial reporting framework often encompasses financial accounting standards promulgated by an authorized or recognized standards-setting organization or legislative or regulatory requirements. In some cases, the financial reporting framework may encompass both financial accounting standards promulgated by an authorized or recognized standards-setting organization and legislative or regulatory requirements. Other sources may provide direction on the application of the applicable financial reporting framework. In some cases, the applicable financial reporting framework may encompass such other sources or may even consist only of such sources. Such other sources may include the following: 7 Agenda Item 2A Page 7 of 20

The legal and ethical environment, including statutes, regulations, court decisions, and professional ethical obligations regarding accounting matters Published accounting interpretations of varying authority issued by standardssetting, professional, or regulatory organizations Published views of varying authority on emerging accounting issues issued by standards-setting, professional, or regulatory organizations General and industry practices widely recognized and prevalent Accounting literature When conflicts exist between the financial reporting framework and the sources from which direction on its application may be obtained, or among the sources that encompass the financial reporting framework, the source with the highest authority prevails. A5. The requirements of the applicable financial reporting framework determine the form and content of the financial statements. Although the framework may not specify how to account for or disclose all transactions or events, it ordinarily embodies sufficiently broad principles that can serve as a basis for developing and applying accounting policies that are consistent with the concepts underlying the requirements of the framework. A6. The financial accounting standards promulgated by organizations that are authorized or recognized to promulgate standards to be used by entities for preparing financial statements in accordance with a general purpose framework include the Financial Accounting Standards Board (FASB) Accounting Standards Codification, issued by FASB; International Financial Reporting Standards, issued by the International Accounting Standards Board; Statements of Federal Financial Accounting Standards, issued by the Federal Accounting Standards Advisory Board for U.S. federal government entities; and Statements of the Governmental Accounting Standards Board, issued by the Governmental Accounting Standards Board for U.S. state and local governmental entities. A7. The requirements of the applicable financial reporting framework also determine what constitutes a complete set of financial statements. In the case of many frameworks, financial statements are intended to provide information about the financial position, financial performance, and cash flows of an entity. For example, a complete set of financial statements might include a balance sheet, an income statement, a statement of changes in equity, a cash flow statement, and related notes. For some other financial reporting frameworks, a single financial statement and the related notes might constitute a complete set of financial statements. Examples of a single financial statement, each of which would include related notes, include the following: Balance sheet Statement of income or statement of operations Statement of retained earnings 8 Agenda Item 2A Page 8 of 20

Statement of cash flows Statement of assets and liabilities Statement of changes in owners equity Statement of revenue and expenses Statement of operations by product lines A8. An accountant may be engaged to compile or review a complete set of financial statements or an individual financial statement (for example, balance sheet only). The financial statements may be for an annual period or for a shorter or longer period, depending on management s needs. However, it is likely not appropriate for the entity to present financial statements for a period longer or shorter than an annual period in a comparative presentation with financial statements for an annual period. A9. Because of the significance of the premise to the conduct of a compilation or review engagement, the accountant is required to obtain management s agreement that they acknowledge and understand that they have the responsibilities set out in paragraph A1 as a precondition for accepting the compilation or review engagement. 3 Three-Party Relationship (Ref: par. 5) Management (Responsible Party) A10. Management is responsible for the preparation and fair presentation of the financial statements in accordance with the applicable financial reporting framework; this responsibility includes the design, implementation, and maintenance of internal control sufficient to provide a reasonable basis for the preparation and fair presentation of financial statements in accordance with the applicable financial reporting frameworkand for designing, implementing, and maintaining internal control. A11. The division of internal control into the following five components, for purposes of SSARSs provides auseful framework for accountants when considering how different aspects of an entity's internal control may affect the compilation or review: a. The control environment b. The entity's risk assessment process c. The information system, including the related business processes relevant to financial reporting and communication d. Control activities 3 Paragraph 6 of the proposed Statement on Standards for Accounting and Review Services (SSARS) Compilation Engagements and paragraph 7 of the proposed SSARS Review of Financial Statements. 9 Agenda Item 2A Page 9 of 20

e. Monitoring of controls The Committee of Sponsoring Organizations of the Treadway Commission defines internal control as a process effected by management (or those charged with governance and other personnel) designed to provide reasonable assurance about the achievement of the entity's objectives. Internal control consists of five interrelated components: 1. Control environment sets the tone of an organization, influencing the control consciousness of its people. It is the foundation for all other components of internal control, providing discipline and structure. 2. Entity's risk assessment is the entity's identification and analysis of relevant risks to achievement of its objectives, forming a basis for determining how the risks should be managed. 3. Information and communication systems support the identification, capture, and exchange of information in a form and time frame that enables people to carry out their responsibilities. 4. Control activities are the policies and procedures that help ensure that management directives are carried out. 5.1.Monitoring is a process that assesses the quality of internal control performance over time. A12. A basic premise underlying the performance of a compilation or review engagement is that the accountant is performing a service on subject matter that is the responsibility of the entity's management. If management does not take responsibility for the subject matter, the accountant s independence is impaired. A13. As part of their responsibility for the preparation and presentation of the financial statements, management is responsible for the identification of the applicable financial reporting framework and the preparation and presentation of the financial statements in accordance with that framework. A14. During the performance of a compilation or review engagement, the accountant may make suggestions about the form or content of the financial statements based on information that is the representation of management. A15. In some cases, management and the intended users may be the same. Intended users may be from different entities (for example, a lender or potential investor) or the same entity (for example, management and those charged with governance). A16. If an accountant is not in public practice, the issuance of a report that states that the accountant performed the engagement in accordance with SSARSs is inappropriate. Intended Users of the Financial Statements or Financial Information 10 Agenda Item 2A Page 10 of 20

A17. The accountant has no responsibility to identify the intended users. A18. In some cases, intended users (for example, lenders and regulators) may impose a requirement on or request the entity to arrange for additional services to be performed for a specific purpose. For example, a lender may request that certain agreed-upon procedures be performed with respect to the entity's accounts receivable in addition to the compilation engagement. An accountant may perform such additional services as long as the accountant adheres to professional standards with respect to those additional services. Ethical Requirements Relating to a Compilation or Review of Financial Statements (Ref: par. 9 and 11) A19. The accountant is subject to relevant ethical requirements relating to compilation or review engagements. Ethical requirements consist of those contained in the AICPA Code of Professional Conduct together with rules of state boards of accountancy and applicable regulatory agencies that are more restrictive. A20. The AICPA Code of Professional Conduct establishes the fundamental principles of professional ethics, which include the following: Responsibilities The public interest Integrity Objectivity and independence Due care Scope and nature of services A21. In the case of a review engagement, it is in the public interest and, therefore, required by this section, that the accountant be independent of the entity subject to the review. The concept of independence refers to both independence in fact and independence in appearance. The accountant s independence from the entity safeguards the accountant s ability to form a review conclusion without being affected by influences that might compromise that opinionconclusion. Independence enhances the accountant s ability to act with integrity, to be objective, and to maintain an attitude of professional skepticism. Independence implies an impartiality that recognizes an obligation to be fair not only to management but also to users of the financial statements who may rely upon the independent accountant s review report. Guidance on threats to independence is set forth in the AICPA s Conceptual Framework for AICPA Independence Standards (ET sec. 100-1). A22. In the case of a compilation engagement, the accountant is not required to be independent because the accountant does not express an opinion, conclusion, or provide any assurance on the financial statements. 11 Agenda Item 2A Page 11 of 20

A23. Due care requires the accountant to discharge professional responsibilities with competence and to have the appropriate capabilities to perform the compilation or review and enable an appropriate accountant s report to be issued, if applicable. A24. QC section 10, A Firm s System of Quality Control (AICPA, Professional Standards), sets out the firm s responsibilities to establish and maintain its system of quality control for compilation and review engagements and to establish policies and procedures designed to provide it with reasonable assurance that the firm and its personnel comply with relevant ethical requirements, including those pertaining to independence. 4 A25. Nothing prohibits an accountant who is unable to complete a review engagement due to a determination that the accountant s independence is impaired from performing a compilation engagement on those financial statements. Professional Judgment (Ref: par. 12) A26. Professional judgment is essential to the proper conduct of a compilation or review because interpretation of relevant ethical requirements and SSARSs and the informed decisions required throughout the engagement cannot be made without the application of relevant knowledge and experience to the facts and circumstances. A27. The distinguishing feature of the professional judgment expected of the accountant is that it is exercised by an accountant whose training, knowledge, and experience have assisted in developing the necessary competencies to achieve reasonable judgments and make informed decisions about appropriate courses of action in undertaking a compilation or review engagement. Consultation on difficult or contentious matters during the course of the engagement, both within the engagement team and between the engagement team and others at the appropriate level within or outside the firm, assists the accountant in making informed and reasonable judgments. A28. The exercise of professional judgment in individual engagements is based on the facts and circumstances that are known by the accountant throughout the engagement, including knowledge acquired from engagements carried out for the entity s financial statements in prior periods, where applicable. the accountant s understanding of the entity and its environment, including its accounting system, and of the application of the applicable financial reporting framework in the entity s industry. the extent to which the preparation and presentation of the financial statements requires the exercise of judgment by management. A29. Professional judgment can be evaluated based on whether the judgment reached reflects a competent application of SSARSs and accounting principles and is appropriate in light 4 Paragraphs.21.25 of QC section 10, A Firm s System of Quality Control (AICPA, Professional Standards). 12 Agenda Item 2A Page 12 of 20

of, and consistent with, the facts and circumstances that were known to the accountant up to the date of the accountant s compilation or review report. A30. Professional judgment needs to be exercised throughout the compilation or review. It also needs to be appropriately documented in accordance with the requirements of the proposed SSARSs Compilation Engagements and Review of Financial Statements. Professional judgment is not to be used as the justification for decisions that are not otherwise supported by the facts and circumstances of the engagement or the evidence obtained. Conduct of an Engagement in Accordance With SSARSs Complying With AR Sections Relevant to the Engagement (Ref: par. 14) A31. ET section 202, Compliance With Standards (AICPA, Professional Standards), requires an AICPA member who performs a compilation or review to comply with standards promulgated by ARSC. ARSC develops and issues standards in the form of SSARSs through a process that includes deliberation in meetings open to the public, public exposure of proposed SSARSs, and a formal vote. The SSARSs are codified in AR sections in AICPA Professional Standards. A32. SSARSs provide the standards for the accountant s work in fulfilling the overall objectives of the accountant. SSARSs address the general responsibilities of the accountant, as well as the accountant s further considerations relevant to the application of those responsibilities to specific topics. A33. The scope, effective date, and any specific limitation of the applicability of a specific AR section are made clear in the AR section. Unless otherwise stated in the AR section, the accountant is permitted to apply an AR section before the effective date specified therein. A34. In certain engagements, the accountant also may be required to comply with other compilation or review requirements in addition to SSARSs. SSARSs do not override law or regulation that governs a compilation or review of financial statements. In the event that such law or regulation differs from SSARSs, a compilation or review conducted only in accordance with law or regulation will not necessarily comply with SSARSs. A35. The accountant may also conduct the compilation or review in accordance with both SSARSs and International Standard on Related Services 4410 (Revised), Compilation Engagements, International Standard on Review Engagements 2400 (Revised), Engagements to Review Historical Financial Statements, or compilation or review standards of a specific jurisdiction or country. In such cases, in addition to complying with each of the AR sections relevant to the engagement, it may be necessary for the accountant to perform additional compilation or review procedures in order to comply with the other compilation or review standards. 13 Agenda Item 2A Page 13 of 20

A36. SSARSs are relevant to compilations and reviews of financial statements of governmental entities. The accountant s responsibilities, however, may be affected by law, regulation, or other authority (such as government policy requirements or resolutions of the legislature), which may encompass a broader scope than a compilation or review of financial statements in accordance with SSARSs. These additional responsibilities are not dealt with in SSARSs. A37. In addition to objectives and requirements, an AR section contains related guidance in the form of application and other explanatory material. It may also contain introductory material that provides context relevant to a proper understanding of the AR section and definitions. The entire text of an AR section, therefore, is relevant to an understanding of the objectives stated in an AR section and the proper application of the requirements of an AR section. A38. When necessary, the application and other explanatory material provides further explanation of the requirements of an AR section and guidance for carrying them out. In particular, it may explain more precisely what a requirement means or is intended to cover. include examples of procedures that may be appropriate in the circumstances. Although such guidance does not in itself impose a requirement, it is relevant to the proper application of the requirements of an AR section. The accountant is required by paragraph 15 to understand the application and other explanatory material; how the accountant applies the guidance in the engagement depends on the exercise of professional judgment in the circumstances consistent with the objective of the AR section. The words may, might, and could are used to describe these actions and procedures. The application and other explanatory material may also provide background information on matters addressed in an AR section. A39. Appendixes form part of the application and other explanatory material. The purpose and intended use of an appendix are explained in the body of the related AR section or within the title and introduction of the appendix itself. A40. Introductory material may include, as needed, such matters as explanation of the following: The purpose and scope of the AR section, including how the AR section relates to other AR sections The subject matter of the AR section The respective responsibilities of the accountant and others in relation to the subject matter of the AR section The context in which the AR section is set A41. An AR section may include, in a separate section under the heading Definitions, a description of the meanings attributed to certain terms for purposes of SSARSs. These are 14 Agenda Item 2A Page 14 of 20

provided to assist in the consistent application and interpretation of SSARSs and are not intended to override definitions that may be established for other purposes, whether in law, regulation, or otherwise. Unless otherwise indicated, those terms will carry the same meanings throughout SSARSs. Complying With Relevant Requirements (Ref: par. 17) A42. Within a relevant AR section, there may be conditional requirements. Such a requirement is relevant when the circumstances envisioned in the requirement apply and the condition exists. In some cases, a requirement may be expressed as being conditional on applicable law or regulation. For example, the accountant may be required to withdraw from the compilation or review engagement, when withdrawal is possible under applicable law or regulation, or the accountant may be required to perform a certain action, unless prohibited by law or regulation. Defining Professional Responsibilities in SSARSs (Ref: par. 18) A43. If an AR section provides that a procedure or action is one that the accountant should consider, consideration of the procedure or action is presumptively required. Whether the accountant performs the procedure or action is based upon the outcome of the accountant s consideration and the accountant's professional judgment. Interpretive Publications (Ref: par. 20) A44. Interpretive publications are not SSARSs. Interpretive publications are recommendations on the application of SSARSs in specific circumstances, including engagements for entities in specialized industries. An interpretive publication is issued under the authority of ARSC only after all ARSC members have been provided an opportunity to consider and comment on whether the proposed interpretive publication is consistent with SSARSs. Compilation and review interpretations of SSARSs and exhibits to SSARSs are included in the AR sections. Other Compilation and Review Publications (Ref: par. 21) A45. Other compilation and review publications have no authoritative status; however, they may help the accountant understand and apply SSARSs. The accountant is not expected to be aware of the full body of other compilation and review publications. A46. Although the accountant determines the relevance of these publications in accordance with paragraph 21, the accountant may presume that other compilation and review publications published by the AICPA that have been reviewed by the AICPA Audit and Attest Standards staff are appropriate. These other compilation and review publications are listed in AR Appendix A, Other Compilation and Review Publications. A47. In determining whether an other compilation and review publication that has not been reviewed by the AICPA Audit and Attest Standards staff is appropriate to the 15 Agenda Item 2A Page 15 of 20

circumstances of the engagement, the accountant may wish to consider the degree to which the publication is recognized as being helpful in understanding and applying SSARSs and the degree to which the issuer or author is recognized as an authority in compilation and review matters. Other compilation and review publications that have not been reviewed by the AICPA Audit and Attest Standards staff that contradict an other compilation and review publication that has been reviewed by the AICPA Audit and Attest Standards staff is inappropriate. Engagement Level Quality Control (Ref: par. 23) A48. Within the context of the firm s system of quality control, engagement teams have a responsibility to implement quality control procedures applicable to the engagement, and provide the firm with relevant information to enable the functioning of that part of the firm s system of quality control relating to independence. A49. The actions of the engagement partner and appropriate messages to the other members of the engagement team, in the context of the engagement partner taking responsibility for the overall quality on each engagement, emphasize the fact that quality is essential in performing a compilation or review engagement, and the importance to the quality of the compilation or review engagement of: (a) Performing work that complies with professional standards and regulatory and legal requirements. (b) Complying with the firm s quality control policies and procedures, as applicable. (c) Issuing a report for the engagement that is appropriate in the circumstances. (d) The engagement team s ability to raise concerns without fear of reprisals. A50. Unless information provided by the firm or other parties suggests otherwise, the engagement team is entitled to rely on the firm s system of quality control. For example, the engagement team may rely on the firm s system of quality control in relation to: Competence of personnel through their recruitment and formal training. Independence through the accumulation and communication of relevant independence information. Maintenance of client relationships through acceptance and continuance systems. Adherence to regulatory and legal requirements through the monitoring process. 16 Agenda Item 2A Page 16 of 20

In considering the deficiencies identified in the firm s system of quality control that may affect the compilation or review engagement, the engagement partner may consider measures taken by the firm to rectify those deficiencies. A51. A deficiency in the firm s system of quality control does not necessarily indicate that a compilation or review engagement was not performed in accordance with professional standards and applicable legal and regulatory requirements, or that the accountant s report was not appropriate. Assignment of Engagement Teams (Ref: par. 23(b)) A52. When considering the appropriate competence and capabilities expected of the engagement team as a whole, the engagement partner may take into consideration such matters as the team s: Understanding of, and practical experience with, compilation and review engagements of a similar nature and complexity through appropriate training and participation. Understanding of professional standards and applicable legal and regulatory requirements. Technical expertise, including expertise with relevant information technology and specialized areas of accounting or attest services. Knowledge of relevant industries in which the client operates. Ability to apply professional judgment. Understanding of the firm s quality control policies and procedures. Acceptance and Continuance of Client Relationships and Compilation or Review Engagements (Ref: par. 23(d)(i)) A53. QC section 10 requires the firm to obtain information considered necessary in the circumstances before accepting an engagement with a new client, when deciding whether to continue an existing engagement, and when considering acceptance of a new engagement with an existing client. Information such as the following assists the engagement partner in determining whether the conclusions reached regarding the acceptance and continuance of client relationships and audit engagements are appropriate: The integrity of the principle owners, key management, and those charged with governance of the entity Whether the engagement team is competent to perform the compilation or review engagement and has the necessary capabilities, including time and resources 17 Agenda Item 2A Page 17 of 20

Whether the firm and the engagement team can comply with relevant ethical requirements Significant findings or issues that have arisen during the current or previous compilation or review engagement and their implications for continuing the relationship A54. If the engagement partner has cause to doubt management s integrity to a degree that is likely to affect proper performance of the compilation or review, it is not appropriate to accept the engagement, unless required by law or regulation, as doing so may lead to the accountant being associated with the entity s financial statements in an inappropriate manner. 18 Agenda Item 2A Page 18 of 20

AR Appendix A Proposed Framework SSARS Redline to show changes from ED Other Compilation and Review Publications This listing identifies other compilation and review publications published by the AICPA that have been reviewed by the AICPA Audit and Attest Standards staff and are, therefore, presumed to be appropriate, as defined in the proposed SSARS Framework for Performing and Reporting on Compilation and Review Engagements. Products may be obtained through www.cpa2biz.com. Current AICPA Alerts Compilation and Review Developments Understanding the Financial Reporting Framework for Small- and Medium-Sized Entities Independence and Ethics Developments AICPA Technical Practice Aids Accounting and Compilation and Review Technical Questions and Answers (TIS) Sections (available in hard copy) SPECIAL PURPOSE FRAMEWORKS Disclosure Concerning Subsequent Events in Special Purpose Financial Statements [TIS 1500.07] Applicability of Fair Value Disclosure Requirements in FASB ASC 820 to Financial Statements Prepared in Accordance With a Special Purpose Framework [TIS 1800.06] COMPILATION AND REVIEW ENGAGEMENTS Financial Statements Marked As Unaudited [TIS 9150.04] Supplementary Information [TIS 9150.08] Applicability of AR Section 300 to Certain Companies Required to File With Regulatory Bodies [TIS 9150.09] Review of Financial Statements Included in a Prescribed Form [TIS 9150.10] Reference to Accountant s Report in Notes to Financial Statements [TIS 9150.16] Bank Engaged an Accountant to Compile a Financial Statement of Another Entity [TIS 9150.18] Reissuance When Not Independent [TIS 9150.20] Issuing a Compilation Report on Financial Statements That Omit Substantially All Disclosures After Issuing a Report on the Same Financial Statements That Include Substantially All Disclosures [TIS 9150.24] Determining Whether Financial Statements Have Been Prepared by the Accountant [TIS 9150.25] The Accountant s Responsibilities for Subsequent Events in Compilation and Review Engagements [TIS 9150.26] 19 Agenda Item 2A Page 19 of 20

The Accountant s Reporting Responsibility With Respect to Subsequent Discovery of Facts Existing at the Date of the Report [TIS 9150.27] Compilation Engagement When the Accountant Is Performing Management Functions [TIS 9150.28] Effects on Compilation and Review Engagements When Management Does Not Assess Whether the Reporting Entity Is the Primary Beneficiary of a Variable Interest Entity and Instructs the Accountant to Not Perform the Assessment [TIS 9150.29] Disclosure of Independence Impairment in the Accountant s Compilation Report on Comparative Financial Statements When the Accountant s Independence Is Impaired in Only One Period [TIS 9150.30] Break-Even Financial Statements [TIS 9150.31] COMPILATION OF FINANCIAL STATEMENTS Omission of Reconciliation of Net Income to Cash Flows From Operations [TIS 1300.17] Compilation and ReviewComparative Financial Statements [TIS 9160.26] Successor Accountant Becomes Aware of Information During the Performance of a Compilation or Review That Leads the Successor Accountant to Believe That Financial Statements Reported On by a Predecessor Accountant Who Has Ceased Operations May Require Revision [TIS 8900.10] Compilation and Review Comparative Financial Statements [TIS 9160.26] COMPILATION REPORTS Omission of Reconciliation of Net Income to Cash Flow From Operations [TIS 1300.17] Omission of Reconciliation of Net Income to Cash Flow From Operations [TIS 1300.17] Statement of Cash Receipts and Disbursements [TIS 9110.07] REVIEW OF FINANCIAL STATEMENTS Successor Accountant Becomes Aware of Information During the Performance of a Compilation or Review That Leads the Successor Accountant to Believe That Financial Statements Reported On by a Predecessor Accountant Who Has Ceased Operations May Require Revision [TIS 8900.10] REVIEW REPORTS Making Reference to Review Report [TIS 8800.30] Statement of Cash Receipts and Disbursements [TIS 9110.07] Other Publications Corporations: Checklists and Illustrative Financial Statements The Engagement Letter: Best Practices and Examples 20 Agenda Item 2A Page 20 of 20